March 5, 2020

Ran Daniel
Chief Financial Officer
Cuentas, Inc.
200 S. Biscayne Blvd., Suite 5500
Miami, FL 33131

       Re: Cuentas, Inc.
           Revised Preliminary Proxy Statement on Schedule 14A
           Filed February 21, 2020
           File No. 000-54923

Dear Mr. Daniel:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Revised Preliminary Proxy Statement on Schedule 14A filed on February 21, 2020

Proposal 1, page 5

1.    We note that you filed a Current Report on Form 8-K in response to our
comment. Please
      tell us whether all relevant exhibits filed in the Form 8-K were accepted
by the Florida
      Division of Corporations. The correspondence from the Florida Division of
Corporations
      included in some of your exhibits appears to suggest that charter
amendments were not
      given effect. For example, we note the correspondence related to Exhibits
3.08 and 3.14.
2.    Please disclose whether setting the number of authorized common shares at
360,000,000
      and authorizing 50,000,000 of blank check preferred stock, as proposed in
the proxy
      statement, would increase, decrease, or leave unchanged the current
number of authorized
      common shares and blank check preferred, respectively. If you are
proposing to increase
      the number of authorized common or blank check preferred in connection
with this proxy,
      please tell us the consideration you have given to Note A of Schedule 14A
of the
      Exchange Act. In the alternative, if the current number of authorized
common shares and
 Ran Daniel
Cuentas, Inc.
March 5, 2020
Page 2
      blank preferred stock will not change, please tell us where the charter
amendments
      authorizing the current number of shares have been filed. In this regard,
we note that your
      Form 8-K filed in response to comment 1 includes multiple exhibits and it
is difficult to
      discern the current number of authorized shares.
Proposal 2, page 10

3.    We note your response to prior comment 2 and reissue the comment in part.
Please clarify
      how the proposed charter amendment would make your bylaws "more
consistent" with
      Florida law, as you assert in the second paragraph of this section and
elsewhere in the
      filing.
4.    Your disclosure in the third paragraph of this section indicates that
while you have
      disclosed "certain" material changes, you do not believe it is practical
to summarize all
      changes proposed to your existing bylaws. Please note that you are
responsible for the
      accuracy and completeness of your disclosure. Therefore, please revise to
remove any
      implication that you have not described all material changes in the
amended and restated
      bylaws of the company and revise to disclose all material changes, as
appropriate.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Daniel Morris at (202) 551-3314 or Jennifer L pez at
(202) 551-3792 with
any other questions.



                                                           Sincerely,
FirstName LastNameRan Daniel
                                                           Division of
Corporation Finance
Comapany NameCuentas, Inc.
                                                           Office of Trade &
Services
March 5, 2020 Page 2
cc:       David Selengut, Esq.
FirstName LastName